AMERICAN SOCIETY FOR TESTING AND MATERIALS et al v. PUBLIC.RESOURCE.ORG, INC.

Filing 105

NOTICE of Proposed Order Regarding the Schedule for Completion of Discovery by PUBLIC.RESOURCE.ORG, INC. re Set/Reset Deadlines (Attachments: #1 Text of Proposed Order Regarding the Schedule for Completion of Discovery)(Bridges, Andrew)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
AMERICAN SOCIETY FOR TESTING AND
MATERIALS d/b/a ASTM INTERNATIONAL;

Case No. 1:13-cv-01215-TSC-DAR

NATIONAL FIRE PROTECTION
ASSOCIATION, INC.; and

PUBLIC.RESOURCE.ORG, INC.’S
NOTICE OF FILING WITH PROPOSED
ORDER REGARDING THE SCHEDULE
FOR COMPLETION OF DISCOVERY

AMERICAN SOCIETY OF HEATING,
REFRIGERATING, AND AIR CONDITIONING
ENGINEERS,
Plaintiffs/Counter-defendants,

Filed:

August 6, 2013

v.
PUBLIC.RESOURCE.ORG, INC.,
Defendant/Counterclaimant.
Public.Resource.Org hereby provides notice to the Court of the attached proposed order,
in response to the Court’s Orders of June 10 and June 16, 2015. Public Resource has met and
conferred with Plaintiffs on three occasions in the past week-and-a-half and exchanged numerous
emails in an effort to reach an agreement. Public Resource has also offered Plaintiffs an
additional one to two weeks to take the deposition of Public Resource’s expert, whose deposition
Plaintiffs noticed only this afternoon, but Plaintiffs have declined that offer. Accordingly, the
proposed order is attached.

Respectfully submitted,

Dated: June 24, 2015

/s/ Andrew P. Bridges
Andrew P. Bridges (admitted)
[e-mail]
Kathleen Lu (pro hac vice)
[e-mail]
Matthew B. Becker (pro hac vice)
[e-mail]
FENWICK & WEST LLP
555 California Street, 12th Floor
San Francisco, CA 94104
Telephone: [phone]
Facsimile: [phone]
David Halperin (D.C. Bar No. 426078)
[e-mail]
1530 P Street NW
Washington, DC 20005
Telephone: [phone]
Mitchell L. Stoltz (D.C. Bar No. 978149)
[e-mail]
Corynne McSherry (pro hac vice)
[e-mail]
ELECTRONIC FRONTIER FOUNDATION
815 Eddy Street
San Francisco, CA 94109
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant-Counterclaimant
Public.Resource.Org, Inc.

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